IN THE CIRCUIT COURT FOR [____] COUNTY, MARYLAND

Civil Action No.: _____

[PLAINTIFF FULL LEGAL NAME],
[Plaintiff’s Street Address]
[City], Maryland [ZIP]
Plaintiff,

v.

[DEFENDANT FULL LEGAL NAME],
[Defendant’s Street Address]
[City], [State] [ZIP]
Defendant.

COMPLAINT FOR PERSONAL INJURIES AND PROPERTY DAMAGE
(DEMAND FOR JURY TRIAL)

[// GUIDANCE: Replace all bracketed placeholders before filing. Ensure the caption complies with Md. Rule 1-301 and local circuit-court formatting requirements.]

TABLE OF CONTENTS

1. Definitions
2. Preliminary Statement
3. Parties
4. Jurisdiction and Venue
5. Statement of Facts
6. Causes of Action
   6.1 Count I – Negligence (Personal Injury)
   6.2 Count II – Negligence (Property Damage)
   6.3 Count III – Loss of Consortium (optional)
7. Damages
8. Compliance with Maryland Statutory Requirements
9. Prayer for Relief
10. Demand for Jury Trial
11. Conditions Precedent & Reservation of Rights
12. General Provisions
13. Verification
14. Certificate of Service

1. DEFINITIONS

For ease of reference, the following capitalized terms shall have the meanings set forth below:

a. “Accident” means the motor-vehicle collision that occurred on [DATE] at or near [LOCATION], Maryland.
b. “Complaint” means this civil pleading filed in the Circuit Court for [_] County, Maryland.
c. “Defendant’s Vehicle” means the [YEAR/MAKE/MODEL], Vehicle Identification Number _, owned and/or operated by Defendant at the time of the Accident.
d. “Plaintiff’s Vehicle” means the [YEAR/MAKE/MODEL], Vehicle Identification Number ____, owned and/or operated by Plaintiff at the time of the Accident.
e. “Statutory Cap” means the limitation on non-economic damages set forth in Md. Code Ann., Cts. & Jud. Proc. § 11-108.

2. PRELIMINARY STATEMENT

1. This is an action for negligence arising out of a motor-vehicle Accident in which Plaintiff sustained serious personal injuries and property damage as a direct and proximate result of Defendant’s tortious conduct.
2. Plaintiff seeks compensation in excess of $75,000.00, exclusive of interest, costs, and attorney’s fees, thereby invoking the original jurisdiction of this Court and the constitutional right to a jury trial.

3. PARTIES

3. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is an adult resident of the State of Maryland, residing at the address stated in the caption.
4. Upon information and belief, Defendant [DEFENDANT NAME] (“Defendant”) is an adult resident of [STATE OF RESIDENCE] who may be served at the address stated in the caption or wherever Defendant may be found pursuant to Md. Rules 2-124 & 2-121.

4. JURISDICTION AND VENUE

5. This Court has subject-matter jurisdiction under Md. Code Ann., Cts. & Jud. Proc. § 1-501 and Md. Const. art. IV, § 20.
6. Venue is proper in this County under Md. Code Ann., Cts. & Jud. Proc. § 6-201 because the causes of action arose here and/or Defendant resides or carries on regular business here.
7. The amount in controversy exceeds the exclusive jurisdictional limit of the District Court of Maryland.

5. STATEMENT OF FACTS

8. On [DATE] at approximately [TIME], Plaintiff was lawfully operating Plaintiff’s Vehicle in a [direction/lane] on [ROADWAY] near [LOCATION] in [COUNTY], Maryland.
9. At that same time and place, Defendant was operating Defendant’s Vehicle in a negligent, careless, and reckless manner, including but not limited to:
   a. Failing to keep a proper lookout;
   b. Traveling at an excessive and/or unreasonable speed;
   c. Failing to maintain proper control;
   d. Violating applicable Maryland traffic laws; and
   e. Colliding with Plaintiff’s Vehicle.
10. As a direct and proximate result of the Accident, Plaintiff suffered severe bodily injuries, including but not limited to [LIST INJURIES], incurred medical expenses, lost wages, property damage, pain, suffering, mental anguish, and other losses.
11. Plaintiff did not contribute to the occurrence of the Accident in any manner.

[// GUIDANCE: Paragraph 11 is critical because Maryland adheres to contributory negligence, a complete bar to recovery if plaintiff is even 1% at fault. Keep this allegation unequivocal.]

6. CAUSES OF ACTION

6.1 Count I – Negligence (Personal Injury)

12. Plaintiff incorporates by reference Paragraphs 1–11 as though fully set forth herein.
13. Defendant owed Plaintiff a duty to operate Defendant’s Vehicle with reasonable care and in accordance with Maryland traffic laws.
14. Defendant breached that duty by the acts and omissions described above.
15. Defendant’s breaches were the direct and proximate cause of Plaintiff’s injuries and damages.
16. As a result, Plaintiff is entitled to recover damages in an amount to be determined at trial.

6.2 Count II – Negligence (Property Damage)

17. Plaintiff incorporates by reference Paragraphs 1–16.
18. Defendant’s negligence caused direct physical damage to Plaintiff’s Vehicle and related personal property, resulting in repair or replacement costs, loss of use, towing, and diminution in value.

6.3 Count III – Loss of Consortium (if applicable)

19. [CONSORTIUM PLAINTIFF NAME], spouse of Plaintiff, incorporates by reference Paragraphs 1–18 and alleges loss of companionship, affection, society, and services as a direct result of the injuries sustained by Plaintiff.

[// GUIDANCE: Delete Count III if no consortium claimant exists. Remember to add the spouse as a named party in the caption and signature block if this count is included.]

7. DAMAGES

20. Plaintiff has incurred and will continue to incur:
    a. Past and future medical expenses estimated at $[_];
    b. Lost wages and diminished earning capacity estimated at $[_];
    c. Property-damage losses estimated at $[__];
    d. Non-economic damages, including pain, suffering, inconvenience, and loss of enjoyment of life, subject to the Statutory Cap; and
    e. Pre- and post-judgment interest, costs, and any other relief deemed just and proper.

[// GUIDANCE: For jury instructions and the verdict sheet, ensure separate lines for economic vs. non-economic damages because of the Statutory Cap.]

8. COMPLIANCE WITH MARYLAND STATUTORY REQUIREMENTS

21. Pursuant to Md. Code Ann., Cts. & Jud. Proc. § 11-108, Plaintiff’s claim for non-economic damages shall not exceed the Statutory Cap applicable to the date of the Accident.
22. Plaintiff has complied with any Personal Injury Protection (“PIP”) notice or coordination-of-benefits requirements and reserves subrogation claims, if any.
23. Plaintiff’s claim is brought entirely in tort; no election of no-fault benefits precludes this suit.

9. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court:

A. Enter judgment in favor of Plaintiff and against Defendant in an amount that exceeds $75,000.00, the exact sum to be proven at trial;
B. Award economic and non-economic damages consistent with Md. Code Ann., Cts. & Jud. Proc. § 11-108;
C. Award pre- and post-judgment interest as allowed by law;
D. Award costs of this action, including reasonable attorney’s fees where permitted; and
E. Grant such other and further relief as the Court deems just and proper.

10. DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all issues so triable as a matter of right under the Maryland Constitution and Md. Rule 2-511.

11. CONDITIONS PRECEDENT & RESERVATION OF RIGHTS

24. All conditions precedent to the filing of this action have occurred, have been performed, or have been waived.
25. Plaintiff reserves the right to amend this Complaint to conform to the evidence and to add additional parties or theories of recovery as discovery may warrant.
26. Plaintiff does not consent to arbitration and expressly objects to any motion to compel arbitration.

12. GENERAL PROVISIONS

27. Nothing in this Complaint shall be construed as a waiver of any right, claim, or defense available to Plaintiff under applicable law.
28. If any provision herein is deemed unenforceable, the remaining provisions shall remain in full force and effect.

13. VERIFICATION

I, [PLAINTIFF NAME], solemnly affirm under the penalties of perjury that the contents of the foregoing Complaint are true to the best of my knowledge, information, and belief.

Date: __ ____
[PLAINTIFF NAME]

14. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this ___ day of ____, 20__, a copy of the foregoing Complaint was served on:

[DEFENSE COUNSEL NAME]
[LAW FIRM]
[ADDRESS]
[EMAIL/FAX]

by ☐ hand delivery ☐ first-class mail ☐ MD E-filing system ☐ other: ____.

[ATTORNEY NAME], Esquire
Maryland Bar No. ____
[LAW FIRM NAME]
[Address]
[Phone] | [Fax] | [Email]
Counsel for Plaintiff

[// GUIDANCE: Replace service method to comply with Md. Rule 1-322 and local e-filing protocols.]

END OF DOCUMENT